Loan repayment to shareholder’s spouse wasn’t constructive distribution Beckley, 130 TC No. 18 (2008) Mike Habib, EA The Tax Court has ruled that payments made by a corporation to the wife of one of its shareholders represented repayment of money she advanced to a predecessor corporation. Despite the absence of…
Final regs include new process for reporting employment tax adjustments and refund claims T.D. 9405, 06/30/2008, Reg. § 31.6011(a)-1, Reg. § 31.6011(a)-4, Reg. § 31.6011(a)-5, Reg. § 31.6205-1, Reg. § 31.6302-1, Reg. § 31.6402(a)-1, Reg. § 31.6413(a)-1, Reg. § 31.6403(a)-2 Mike Habib, EA IRS has issued final regs on employment…
Final regs include new process for reporting employment tax adjustments and refund claims T.D. 9405, 06/30/2008, Reg. § 31.6011(a)-1, Reg. § 31.6011(a)-4, Reg. § 31.6011(a)-5, Reg. § 31.6205-1, Reg. § 31.6302-1, Reg. § 31.6402(a)-1, Reg. § 31.6413(a)-1, Reg. § 31.6403(a)-2 Mike Habib, EA IRS has issued final regs on employment…
Gain from selling carbon dioxide allowances didn’t generate foreign personal holding company income PLR 200825009 Mike Habib, EA IRS has privately ruled that gain from the sale of surplus carbon dioxide allowances didn’t constitute foreign personal holding company income (FPHCI) under Code Sec. 954(c). It concluded that the emissions allowances…
House Subcommittee Passes IRS Funding Bill The House Appropriations Financial Services Subcommittee this week passed a bill that would appropriate $11.4 billion to IRS for FY 2009. The bill would grant IRS budget authority to spend $5.1 billion on enforcement, $2.2 on taxpayer services, and $3.8 billion on operations. The…
Business Provisions of the Economic Stimulus Act of 2008 Mike Habib, EA The Economic Stimulus Act of 2008 contains two provisions that provide tax benefits for businesses. The first provision increases the limit up to which a business can expense property purchased and placed in service during its 2008 tax…
More disaster victims in Indiana, Iowa and Wisconsin qualify for tax relief IRS website [https://www.irs.gov/newsroom/article/0,,id=108362,00.html] Mike Habib, EA IRS has announced on its website that additional counties in Indiana, Iowa and Wisconsin have been declared disaster areas on account of recent severe storms, tornadoes and flooding. As a result, more…
Regs crack down on tax avoidance repatriations of CFC earnings Preamble to TD 9402, 06/23/2008; Reg. § 1.956-1T; Preamble to Prop Reg 06/23/2008; Prop Reg § 1.956-1 Mike Habib, EA IRS has issued temporary and proposed regs to determine the basis of certain U.S. property acquired by a controlled foreign…
Business standard mileage rate increases for last half of 2008 – other rates also rise Mike Habib, EA IRS has announced that the optional mileage allowance for owned or leased autos (including vans, pickups or panel trucks) will increase 8¢ from 50.5¢ to 58.5¢ per mile for business travel from…
<span Tax Settlements – As Seen On TV Mike Habib, EA Many Tax Relief and Tax Negotiation firms advertise on TV claiming that they can settle your tax debt for “pennies on the dollar”. Now, you, as a taxpayer must be informed of what options you have and should research…